Draft Bradford District Local Plan - Preferred Options (Regulation 18) February 2021

Object

Representation ID: 19810

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

This section of the Local Plan makes no reference to the need to achieve much higher housing densities than are proposed in this plan for Shipley – for example - in order to avoid the use of greenbelt and greenfield sites for housing and / or to mitigate the need to do so.

We note that the Campaign for the Protection of Rural England has previously suggested that 50dph is a minimum reasonable target to aim for in general and especially when considering the use of non-brownfield sites for housing (see CPRE publication, ‘Compact Sustainable Communities’, November 2006, p.3).

Object

Representation ID: 19811

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The target date for net zero carbon should be brought forward from 2038 to 2030.

SP9 A3 should be strengthened to ensure that the developers demonstrate that their proposals are carbon neutral or carbon negative in relation to construction, building energy use (see below) and travel.

A number of specific measures that developers should be required to incorporated into all developments are provided relating to
- opportunities for both natural heating and ventilation and reducing exposure to wind and other elements;
- maximise resistance and resilience to climate change e.g. solar shading, thermal mass, heating and ventilation, appropriately coloured materials, green and brown roofs, green walls, etc;
- use of trees and other planting to provide shading, to connect habitat with carefully selected native plants
- minimising the impact of surface water runoff from the development in the design of the drainage system

Object

Representation ID: 19812

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

This policy is very welcome, but needs to be significantly strengthened in order to deliver net zero carbon by 2030.

Example wording from Merton Local Plan is given.

EN10 states that the Council and its partners will “maximise” improvements in energy conservation etc, yet then states that zero carbon standards will only need to be met for developments of fifty plus houses. This is a striking contradiction - all new developments (residential and non-residential) should achieve zero carbon standards.

There is almost nothing specific in EN10 on heating. A proposed policy on heat supply is provided.

The plan should also include a policy that states:
Houses should not be built that lock homeowners into the gas network for heating.

Other LA's have adopted more far-reaching policies on low carbon building - Take the example of the ‘Merton Rule’, adopted by Merton Borough Council eighteen years ago in 2003 - The ‘rule’ states that all new developments should generate at least 10% of their energy requirements from on-site renewable energy.

Object

Representation ID: 19813

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

The majority of the housing allocations for Shipley are well-judged i.e. the brownfield sites however:

- Shipley proposals should be limited to brownfield site only to avoid losing green filed and green belt land;
- the council - in the light of post covid implications - review unneeded office spaces and re-designate for residential;
- the brownfield housing allocations for Shipley need to be reviewed in order to achieve significantly higher densities - 50dph minimum;
- the Council should abandon Valley Rd road widening schemes and utilise the land instead for housing;
- all new housing in Shipley should be net zero in line worth putting dealing with the climate crisis at the heart of the plan.

Object

Representation ID: 19814

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

- loss a values area of greenspace
- The site is relatively open and offers valuable views from several vantage points for local residents
- contravenes Public Health England (PHE) in their 2020 document ‘Improving Access to Greenspace’
- contravenes part of Outcome 4 of Bradford’s Joint Health and Wellbeing Strategy 2018-2023
- the council itself has stated that Shipley has a deficit of Amenity Greenspace
- the site fails to account properly for the significant adverse environmental impacts of this housing proposal on the local road network
- for the reasons stated above, we ask that Bradford Council’s Local Plan designates this area as Local Green Space, as laid out in paragraphs 99 and 100 of the NPPF.
- for the reasons stated above, we also ask that Bradford Council formally endorses this area of land as an ‘asset of community value’

Object

Representation ID: 19815

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

- loss of a valued area of open land / green belt which offers beautiful views in / out of the site
- contravenes Public Health England (PHE) in their 2020 document ‘Improving Access to Greenspace’
- contravenes part of Outcome 4 of Bradford’s Joint Health and Wellbeing Strategy 2018-2023
- no exceptional circumstances to change green belt boundary - requires prioritising brownfield sites and also discussions should take place or be shown to the community to have taken place with neighbouring authorities about whether they could accommodate some of the identified need for development;
- merger of settlements - Shipley / Bingley / Cottingley
- loss of trees and wildlife habitats - contravenes various strategies and policy documents ;
- impact on water quality - acknowledged in LP;
- will exacerbate flood risk;
- impact on local road network / traffic /. noise / air pollution
- impact on services and infrastructure, schools over subscribed
- the site is highly unlikely to make a sufficient contribution to meeting social housing need in our area

Object

Representation ID: 19816

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

- loss of a valued area of open land / green belt, loss of beautiful views in / out of the site / impact on public rights of way
- loss of open landscape buffer between Shipley and Cottingley and contravenes several documents / strategic - Public Health England (PHE) etc.
- no exceptional circumstances to change green belt boundary - requires prioritising brownfield sites and also discussions should take place or be shown to the community to have taken place with neighbouring authorities about whether they could accommodate some of the identified need for development;
- loss of trees and wildlife habitats - contravenes various strategies and policy documents ;
- will exacerbate flood risk;
- impact on local road network / traffic /. noise / air pollution
- impact on services and infrastructure, schools over subscribed
- the site is highly unlikely to make a sufficient contribution to meeting social housing need in our area

Object

Representation ID: 19817

Received: 24/03/2021

Respondent: Bradford District Ward Councillor (Green)

Number of people: 2

- loss of a valued area of open land / green belt, loss of beautiful views in / out of the site / impact on public rights of way
- loss of open landscape buffer between Shipley and Cottingley and contravenes several documents / strategic - Public Health England (PHE) etc.
- no exceptional circumstances to change green belt boundary - requires prioritising brownfield sites and also discussions should take place or be shown to the community to have taken place with neighbouring authorities about whether they could accommodate some of the identified need for development;
- loss of trees and wildlife habitats - contravenes various strategies and policy documents ;
- will exacerbate flood risk;
- impact on local road network / traffic /. noise / air pollution
- impact on services and infrastructure, schools over subscribed
- the site is highly unlikely to make a sufficient contribution to meeting social housing need in our area